Part One: Spatial Strategy and Policies (Regulation 18)

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Comment

Part One: Spatial Strategy and Policies (Regulation 18)

Policy DLP1 Development Strategy

Representation ID: 39

Received: 07/12/2023

Respondent: Birmingham and Black Country Wildlife Trust

Representation Summary:

Typological error between 1C and 1D.

Comment

Part One: Spatial Strategy and Policies (Regulation 18)

Policy DLP31 Nature Conservation

Representation ID: 40

Received: 07/12/2023

Respondent: Birmingham and Black Country Wildlife Trust

Representation Summary:

- A Local Wildlife Site Assessment should be required in support of a planning application if it is likely to impact a SINC or a SLINC. Assessments may also be required where a site isn't designated, but there is evidence that these could be of importance (e.g.: Potential Sites of Interest)
- Proper nomenclature for EcoRecord is 'Local Environmental Records Centre'

Comment

Part One: Spatial Strategy and Policies (Regulation 18)

Policy DLP32 Nature Recovery Network and Biodiversity Net Gain

Representation ID: 41

Received: 07/12/2023

Respondent: Birmingham and Black Country Wildlife Trust

Representation Summary:

- Suggest that a more appropriate for this policy may be 'Local Nature Recovery Strategy and Biodiversity Net Gain'
- Suggest that point 4 is reworded to 'Development that is likely to have a negative impact on biodiversity'
- 'Local' in the context of point 8 should be defined somewhere in this document
- We would encourage Dudley MBC to consider requiring a higher than 10% minimum biodiversity net gain for all development

Comment

Part One: Spatial Strategy and Policies (Regulation 18)

Policy DLP33 Provision, retention and protection of trees, woodlands, Ancient Woodland, and Veteran trees

Representation ID: 42

Received: 07/12/2023

Respondent: Birmingham and Black Country Wildlife Trust

Representation Summary:

- In point 4, clarity is sought in what is defined as 'appropriate' location for trees in this context
- In point 25, clarity is sought in what is defined as an 'ecologically important' area in this context

Comment

Part One: Spatial Strategy and Policies (Regulation 18)

Policy DLP39 Design Quality

Representation ID: 43

Received: 07/12/2023

Respondent: Birmingham and Black Country Wildlife Trust

Representation Summary:

- Suggest that point 5 of this policy should aim for the design of new development to integrate into green and blue infrastructure, in order to strengthen these links borough-wide and tie in to the Local Nature Recovery Network

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